Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Classification of imported goods - items imported for deployment in their ‘motorcycle’ production lines - Usage as determinant, or subsuming within broader descriptions, must have specific sanction of the notes as laid down in rule 1 of the General Rules for the Interpretation of Import Tariff. It is also clear from the Rules that the comparison should be at ‘heading’ level before proceeding within the more appropriate of the two for identification of the applicable sub-heading and tariff item - the proposed heading is that of ‘parts and accessories’ of vehicles. - AT
Classification of imported goods - items imported for deployment in their ‘motorcycle’ production lines - Usage as determinant, or subsuming within broader descriptions, must have specific sanction of the notes as laid down in rule 1 of the General Rules for the Interpretation of Import Tariff. It is also clear from the Rules that the comparison should be at ‘heading’ level before proceeding within the more appropriate of the two for identification of the applicable sub-heading and tariff item - the proposed heading is that of ‘parts and accessories’ of vehicles. - AT
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